1. Your rights in relation to privacy

Anywhere Physio Pty Ltd ACN 665 049 981trading as Enzi Physio (“Enzi Physio”, “we”, “us”, “our”) understands the importance of protecting and respecting the privacy of an individual’s personal information.  

This policy (together with our Terms and any other documents referred to in it) sets out how Enzi Physio aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Enzi Physio and the way Enzi Physio collects, holds, uses and discloses your personal information.

In handling your personal information, Enzi Physio complies with the Privacy Act 1988 (Cth) (Privacy Act), the 13 Australian Privacy Principles in the Privacy Act and all other relevant Australian privacy and health records laws.

This policy applies to all individuals about whom Enzi Physio collects personal information including patients, surgeons, referring doctors, other health professionals, potential employees, contractors, suppliers, service providers engaged by us and other individuals engaged by or providing services to Enzi Physio.

This policy may be updated from time to time.

2. What kinds of personal information does Enzi Physio collect?

Personal information is information or an opinion about an identified, or reasonably identifiable, individual.   Health information is a subset of personal information and includes information or an opinion about: 

• the health or disability of an individual; or
• an individual’s expressed wishes about the future provision of health services to them; or
• a health service provided or to be provided to an individual.

Enzi Physio may collect your personal information during the provision of its products and/or services.  The products and/or services provided by Enzi Physio include the provision of health information, physiotherapy services (including treatment plans) and physiotherapy products.

Generally, the kinds of personal information Enzi Physio collects are:

1. contact and identification information such as your name, address, telephone number, email address, date of birth, or other types of verification details; 
2. if you are a medical practitioner, your medical registration details;
3. health information where you are a patient including:

• where you consent to the collection of such information and if relevant to the provision of our products and/or services; 
• information about your health history, family history, ethnic background and current lifestyle; 
• health records, including digital surgical records and digital consultation records; 
• notes about your diagnosis; 
• your treating team’s contact information, and specialist reports and test results; 
• information about your operation or health service you have had/received or will have/receive; 
• appointment and billing details; 
• your Medicare number and health insurance details (if applicable); 

4. where you are applying for a position with Enzi Physio, information that is relevant to Enzi Physio’s assessment of whether you are able to perform the inherent requirements of the particular role, including your education, qualifications, experience and work history, and health information; and
5. other information required for Enzi Physio’s functions and activities, including where required by law.

In some circumstances Enzi Physio may also hold other personal information provided by you or by third parties on your behalf.

3. How does Enzi Physio collect personal information?

Where possible, Enzi Physio collects your personal information directly from you (if you are a patient), through the completion of a form or by way of interaction through our website, telephone, video conference, facsimile, email or post. 

If you are a patient, there may be occasions when Enzi Physio collects your personal information from third parties and other sources such as from: 

1. a referring medical practitioner or nominated general practitioner; 
2. other health service providers or health professionals who provide health care to you; 
3. health care workers involved in, or consulted in relation to, your treatment and associated administration (for example, radiology services); or 
4. a hospital where you receive health care. 

If you are not a patient, Enzi Physio may collect your personal information from third parties and other sources such as from:

1. an entity you represent, where necessary for Enzi Physio to provide its products or services to that entity through you or where necessary for that entity to supply products or services to Enzi Physio; 
2. an information services provider;
3. a publicly maintained record or other publicly available sources of information including social media and similar websites, such as LinkedIn; or 
4. if for recruitment purposes, an external recruitment, labour hire, or background screening services provider or third parties with whom you have previously worked. 

Generally, Enzi Physio will only collect your personal information from sources (including third parties) other than you if it is unreasonable or impracticable to collect personal information directly from you.  

2. Why does Enzi Physio need your personal information?

If you are a patient, Enzi Physio collects, holds, uses and discloses your personal information for the purpose of enabling Enzi Physio to provide you with health care and for directly related purposes.  . 

For patients, Enzi Physio may also collect, hold, use and disclose your personal information for the one or more of the following purposes: 

1. providing Enzi Physio products and/or services to you (or the organisation you represent) and all associated purposes including:
   1. to verify your identity and contact details; 
   2. for invoicing and administrative purposes;
   3. to respond to any inquiries, feedback or complaints made by you; and 
   4. engaging with you in your dealings with Enzi Physio; 
2. enabling Enzi Physio to promote its products and services to you if you are a potential future patient;  
3. assisting Enzi Physio to improve its products and services;
4. invoicing, billing and other internal administrative purposes;
5. otherwise managing Enzi Physio’s internal business operations and processes; 
6. complying with legal requirements; and/or
7. providing information to an insurer or a court if required in the event of actual or anticipated legal proceedings. 

For potential employees, Enzi Physio may collect, hold, use and disclose your personal information for the purposes of:

1. processing and assessing employment applications for current and future positions; 
2. your employment with Enzi Physio; and
3. matters which are permitted or required by law.

Enzi Physio may also use your personal information for purposes related to the above purposes (and where the information is health information, directed related to the above purposes) and for which you would reasonably expect Enzi Physio to do so in the circumstances, or where you have consented, or the use is otherwise in accordance with law.  

Where personal information is used or disclosed, Enzi Physio takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.  You are under no obligation to provide your personal information to Enzi Physio, and your consent may be withdrawn at any time.  However, without certain information from you, Enzi Physio may not be able to provide its products and/or services to you.

3. To whom does Enzi Physio disclose your personal information?

Enzi Physio discloses your personal information for the purpose for which Enzi Physio collects it.  That is, generally, Enzi Physio will only disclose your personal information for a purpose set out at paragraph 4.  This may include disclosing your personal information to:

1. if you are a patient:
   1. a referring medical practitioner or nominated general practitioner; 
   2. other health care workers involved in, or consulted in relation to, your treatment and associated administration (for example, radiology services);  
   3. other health service providers and health professionals that provide your treatment; 
   4. a hospital where you receive health care; 
   5. a third party provider (for example a rehabilitation provider); 
   6. other health service providers in the event of an emergency where you are not able to provide consent; 
   7. physiotherapy students and trainees; 
2. third parties engaged to perform administrative or other business management functions;
3. people or entities considering acquiring an interest in Enzi Physio’s enterprise or assets (noting that Enzi Physio would not disclose health information or other sensitive information during this process);
4. Enzi Physio’s professional advisors, agents, contractors, consultants and related bodies corporate;
5. insurance providers;
6. recruitment and labour hire agencies (as required); 
7. regulatory bodies if and as necessary, including during audit processes; and
8. as required by law.

Enzi Physio disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law.  Enzi Physio may also disclose your personal information with your consent or if disclosure is required or authorised by law.

4. Overseas disclosures

Enzi Physio is not likely to disclose any personal information to overseas recipients.

However, if Enzi Physio becomes likely to disclose personal information to any recipients located overseas, Enzi Physio will update this privacy policy regarding the likely disclosures (including, if it is practicable to do so, the countries in which such overseas recipients are likely to be located).

Enzi Physio may store personal information ‘in the cloud’, which may mean that is resides on servers which are situated outside Australia.  If you have any queries or objections regarding the storage of personal information, please contact us on the details set out in paragraph 12. 

5. Direct marketing 

Enzi Physio may collect, hold, use and disclose personal information in order to inform interested persons or entities of products and services offered by Enzi Physio or to facilitate business relationships.  Enzi Physio would never use health information or other sensitive information for direct marketing purposes. 

Individuals can opt-out of receiving such communications by contacting Enzi Physio on the contact details set out in paragraph 12 or through any opt-out mechanism contained in a marketing communication.  

6. Security of your personal information

Enzi Physio takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference, and loss and from unauthorised access, modification, or disclosure.  

Enzi Physio holds personal information in electronic form in secure databases, accessible only by authorised users.  

Enzi Physio will destroy or de-identify personal information in circumstances where it is no longer required, unless Enzi Physio is otherwise required or authorised by law to retain the information.  

7. Can you access and correct the personal information that Enzi Physio holds about you? 

Enzi Physio takes steps reasonable in the circumstances to ensure the personal information it holds is accurate, up-to-date, complete, relevant and not misleading.  Under the Privacy Act and other applicable privacy and health records legislation, you have a right to access and seek correction of your personal information that is collected and held by Enzi Physio.  

If at any time you would like to access or correct the personal information that Enzi Physio holds about you, or you would like more information on Enzi Physio’s approach to privacy, please contact Enzi Physio’s Privacy Compliance Officer on the details set out in paragraph 12 below.  

Enzi Physio will grant access to the extent required or authorised by the Privacy Act and other applicable privacy and health records legislation, and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.  

To obtain access to your personal information:

1. you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
2. Enzi Physio requests that you be reasonably specific about the information you require; and
3. Enzi Physio may charge you a reasonable administration fee, which reflects the cost to Enzi Physio for providing access in accordance with your request.

Enzi Physio will endeavour to respond to your request to access or correct your personal information within 30 days from your request or as otherwise required by law.

8. Cookies

When accessing Enzi Physio’s website, Enzi Physio may use ‘cookies’ which are small pieces of information sent from the website and stored by your browser on your computer’s hard drive.  Cookies that Enzi Physio may use enable its systems to provide features of its services, personalize and improve your experience, and improve the functionality and user-friendliness of its services and monitor how its website is used through your computer. 

This information may be used by Enzi Physio to improve and tailor its website functionality and better understand how you interact with Enzi Physio’s products and services and to monitor aggregate usage and web traffic routing on its website. You can modify your browser setting by editing your browser options to reject Enzi Physio’s cookies or to prompt you before accepting a cookie.  However, if a browser does not accept cookies or if you reject a cookie, some portions of Enzi Physio’s online services may not function properly. 

9. How to contact us

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Enzi Physio’s Privacy Compliance Officer at: privacy@enziphysio.com.au

10. Privacy complaints

Please direct all privacy complaints to Enzi Physio’s Privacy Compliance Officer.  At all times, privacy complaints:

1. will be treated seriously;
2. will be dealt with promptly;
3. will be dealt with in a confidential manner; and
4. will not affect your existing obligations or affect the commercial arrangements between you and Enzi Physio.

Enzi Physio’s Privacy Compliance Officer will commence an investigation into your complaint.  You will be informed of the outcome of your complaint following completion of the investigation.  In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner or the relevant health records authority.